1. Introduction

This Anti-Money Laundering (AML) Policy is established to prevent, detect, and report money laundering activities and ensure compliance with applicable AML laws and regulations. This policy applies to all employees, agents, and contractors of ATDFIN.

2. Purpose

The purpose of this policy is to:

1. Protect the company from being used for money laundering.

2. Ensure compliance with national and international AML regulations.

3. Maintain the company’s reputation and integrity in the financial system.

3. Scope

This policy applies to all operations and activities of ATDFIN, including:

Customer onboarding.

Transaction monitoring.

Reporting suspicious activities.

4. Definitions

Money Laundering: The process of disguising the origin of illegally obtained money.

Suspicious Activity Report (SAR): A report submitted to the relevant authorities about suspicious transactions.

5. Responsibilities

Compliance Officer: is designated as the Compliance Officer, responsible for overseeing the implementation of this AML Policy.

Employees: All employees must adhere to this policy and report suspicious activities to the Compliance Officer.

6. Customer Due Diligence (CDD)

Verify customer identity before establishing a business relationship.

Obtain information about the purpose and nature of the business relationship.

Conduct enhanced due diligence for high-risk customers.

7. Transaction Monitoring

Monitor transactions for patterns indicative of money laundering.

Identify transactions that exceed predefined thresholds.

Investigate transactions with inconsistent or unusual activity.

8. Reporting

File Suspicious Activity Reports (SARs) to [הרשות המתאימה, כמו הרשות לאיסור הלבנת הון בישראל].

Maintain confidentiality when reporting suspicious activities.

9. Record Keeping

Retain customer records and transaction data for at least [מספר שנים לפי דרישות החוק].

Ensure records are accessible for audits or regulatory inspections.

10. Training

Conduct regular AML training for all employees.

Include updates on regulatory changes and emerging money laundering threats.

11. Penalties for Non-Compliance

Non-compliance with this policy may result in disciplinary actions, including termination of employment, and could expose the company to legal and financial penalties.

12. Review and Updates

This policy will be reviewed annually and updated as necessary to reflect changes in AML regulations or business practices.

Date of Issue: 1.1.2025
Approved by: itay Jacob Ettedgui